Tax service proposes a new tool against invoice blocking

The State Tax Service is changing its approach to blocking VAT invoices: instead of a purely punitive model it is introducing a preventive tool — “roadmaps” for VAT payers that explain how to complete and submit the Data Table in order to minimise the risk of automatic blocking.
Why blocking VAT invoices remains a problem
The SMKOR risk‑monitoring system blocks VAT invoices based on formal criteria such as mismatched business activity codes, lack of stock, “risky” counterparties, sharp jumps in volumes or technical errors. For businesses this means broken supply chains, the buyer losing input VAT credit and funds being frozen. Although, according to the tax service, the share of blocked invoices has been reduced to 0.1–0.15% of all registrations, in absolute terms this still represents thousands of documents, especially in sectors with many small‑value transactions.
Essence of the new tool: roadmaps for the Data Table
· The tax service is focusing on the VAT Taxpayer Data Table, which shows a business’s typical purchases and sales; once the Table is accepted, most transactions can be registered without suspension.
· Common issues include the Table not being filed at all or being filled in only formally, without a description of the business model, references to reporting or reflection of the enterprise’s real resources.
· Based on typical mistakes and business feedback, the tax service has developed step‑by‑step roadmaps for specific types of activity.
· These instructions explain how to describe business operations and link customs and service codes to real‑life transactions.
· They list which contracts, reports and accounting data should be cited in explanations.
· They show which indicators for staff numbers, fixed assets and wages look suspicious to the tax authority.
· The purpose of the roadmaps is to translate the “language” of SMKOR into clear instructions for business so that companies can correctly present the tax reality of their operations and their typical economics.
Most common errors leading to rejection of the Data Table
Alongside the launch of the roadmaps the tax service has published a list of the most frequent mistakes that cause the Data Table not to be accepted:
– submitting the Table with no explanation of the taxpayer’s activity;
– explanations that contain no description of business operations and no references to reports, contracts or primary documents;
– too few employees or wages that are too low for the declared volumes of work;
– discrepancies between information in the Table and data from automated systems (the VAT invoice register, reporting, stock data and the taxpayer’s compliance history).
Taxpayers often treat the Table as a mere formality, whereas for SMKOR it is the key source of information about their “normal” business model. The new tool is meant to encourage businesses to complete this document not just for the sake of form, but as a strategic element of tax security.
How the roadmaps are intended to reduce blocking risk
In the tax service’s concept, the roadmaps should function as a checklist for accountants and owners: if the Table is completed according to the recommended logic, the risk of blocking is significantly reduced. The idea is to:
– eliminate technical errors (incorrect codes, incomplete explanations, lack of links to reporting);
– align the activities shown in the Table with business‑activity codes, staffing levels and accounting data;
– explain to the tax authority the economics of a typical transaction in the relevant sector (construction, agriculture, transport services, fuel trading, etc.).
As a result, SMKOR receives a higher‑quality data set on the taxpayer and triggers less often on “formal risk”, where the business is not actually breaking the law but looks suspicious because of inaccurate information filing.
Limitations and risks of the new approach
Despite the positive signal, the new tool does not resolve every issue: SMKOR’s risk criteria remain opaque, and acceptance of the Data Table does not rule out blocking in cases of sharp volume changes or dealings with “risky” counterparties. For complex business models the roadmaps are only a starting point, so individual analysis and professional support are still needed.
How businesses can use the roadmaps in practice
From a tax‑risk‑management perspective the new tool should be seen as an opportunity to organise relations with the tax service and at the same time carry out an internal audit of VAT processes. It is useful to:

1. analyse your own invoice‑blocking cases over recent years — which product codes, counterparties and volumes caused the most problems;
2. compare these cases with the roadmap recommendations for your sector and identify what needs to be improved in the Data Table and explanations;
3. update activity codes, HR data and information on fixed assets so they do not contradict the activities declared in the Table;
4. build an internal checklist so that, before submitting a new Table or large VAT invoices, you verify consistency between accounting data, reporting and your electronic taxpayer cabinet.
   This approach not only reduces the risk of blocking but also makes the business more transparent to supervisory bodies, which, under increasing fiscal pressure, can become a competitive advantage.

Conclusion
The launch of the tax service’s roadmaps is a step towards more predictable interaction with VAT payers and should reduce the number of blockings caused by basic mistakes and misunderstandings. At the same time, it is not a magic “anti‑blocking button”: companies, especially in high‑risk sectors, must still carefully monitor their counterparties, document quality and data consistency across all systems.
If you have questions or difficulties related to blocked VAT invoices, completing the VAT Taxpayer Data Table or appealing tax‑authority decisions, you should seek advice from tax consultants and legal professionals in order to choose an optimal defence strategy and minimise risks for your business.

Author – Maksym Bahniuk, Head of Tax and Customs Law Practice at WINNER Law Firm.